Court Dismisses Petitions Challenging Rejection of Candidates with Non-Zoology Degrees
The Madhya Pradesh High Court, Indore bench, has delivered a significant judgment reinforcing the sanctity of recruitment advertisements and qualifications prescribed therein. In a consolidated decision involving multiple writ petitions, the court upheld the actions of the Madhya Pradesh Public Service Commission (MPPSC) and the Higher Education Department (HED) in rejecting candidates for the post of Assistant Professor in Zoology.
Presided over by Justice Jai Kumar Pillai, the court dismissed the petitions filed by Dr. Rahul Patidar and others, who challenged their disqualification based on their academic credentials. The core issue revolved around the eligibility criteria specified in the recruitment advertisement, which mandated a Master's Degree in Zoology or its recognized allied subjects, along with a NET qualification in Life Sciences.
The petitioners, possessing degrees in Agriculture Entomology, argued that their qualifications should be considered allied to Zoology. However, the court found that the petitioners did not meet the explicit educational requirements, as their qualifications were not listed among the recognized allied subjects specified in the advertisement.
The judgment emphasized that the prescription of qualifications is a policy matter within the exclusive domain of the employer and not subject to judicial review. The court cited the Supreme Court's precedent in Zahoor Ahmad Rathor v. Sheikh Imtiyaz Ahmad, reiterating that courts cannot act as appellate academic bodies to evaluate the equivalence of qualifications.
Additionally, the court highlighted the importance of maintaining the sanctity of recruitment advertisements. Allowing changes or relaxations in qualifications mid-process would prejudice potential applicants who adhered to the advertised criteria, thereby undermining the principles of equality enshrined in Articles 14 and 16 of the Constitution of India.
The court also dismissed the petitioners' reliance on the UGC Regulations, noting that qualifying exams like NET/SET cannot override specific recruitment rules. The state is empowered to tailor educational qualifications to meet public service needs, and the UGC does not restrict the state's ability to prescribe its own criteria.
Ultimately, the court found no legal, procedural, or constitutional infirmity in the actions of the respondents. The rejection of the petitioners' candidature was deemed justified, and the writ petitions were dismissed without any order as to costs.
Bottom line:-
Eligibility criteria prescribed in recruitment advertisements cannot be altered or relaxed mid-process, even if academic qualifications are claimed to be allied subjects by the candidates.
Statutory provision(s): Article 226 of the Constitution of India, Articles 14 and 16 of the Constitution of India, UGC Regulations, 2018.
Dr. Rahul Patidar v. State of Madhya Pradesh, (Madhya Pradesh)(Indore) : Law Finder Doc id # 2934576
